APCO Project 39 considers its future as meeting dissects 800 MHz proposals
Committee reports progress to date, ponders future
Bob Gurss reviews rebanding proposals
FCC may not take another step this year
Interference reporting tool may get upgrade, new home
APCO’s Project 39 Steering Committee met yesterday at the membership association’s national conference in Nashville, Tenn. The committee’s new chairman, Kevin Kearns, led the two-hour meeting. Kearns, also chairman of P39’s Technical Committee, replaced the committee’s founding chairman, RoxAnn Brown.
At the outset, Kearns said that one objective of the meeting would be to review possible future roles for the committee, including whether P39 should continue. P39 was formed to study interference to public safety radio communications systems in the 800 MHz band, report its findings at six-month intervals and recommend short-term, mid-term and long-term solutions.
Events seemed to take the interference matter out of P39’s grasp almost as soon as the committee was formed.
For example, within its months of existence, a lack of funding for rigorous engineering studies left the committee reluctant to draw firm conclusions based on collected evidence more anecdotal than scientific. A number of public safety agencies in Orange County, Calif., and the city of Portland and the county of Washington in Oregon had applied some remedies. Nextel Communications issued a White Paper analysis of the problem. The FCC issued a Notice of Proposed Rulemaking and asked for comments in the matter.
Interest in P39 on the part of wireless carriers, private radio system operators and manufacturers cooled as they found themselves obliged to defend their financial interests in the 800 MHz band in the face of an FCC proceeding that might include funding only for public safety agencies. The frequency relocation funding question has driven a wedge between public safety and non-public safety interests.
“I see P39 as having an ongoing role,” said Gary David Gray, a Technical Committee member from Orange County. “Whatever the FCC sees as proper course for us, we will still have an interference issue. The physics doesn’t change just because rules change. It will require working with the FCC and regional planning committees if the NPSPAC band is switched to a different allocation.”
Brown, P39’s former chairman, said: “I don’t want project to go on forever. But there are still some developments expected during the next 12 months that the committee should evaluate, such as the validity of ‘black box’ solutions in the works from manufacturers.”
She said that the committee’s future work might not be as intensive as its initial effort, which she described as accomplishing two years’ work in eight months.
Robert M. Gurss, an attorney with Shook, Hardy & Bacon, Washington, who represents APCO, reviewed a compromise proposal for rebanding the 800 MHz band that APCO submitted in conjunction with various public safety and private wireless membership organizations and individual companies.
“The key part is that public safety doesn’t have to move without funding. No individual region would start the move until funding is in place for the entire region. The priority would be by regions with the most interference, followed by those with the most population, and ending with everyone else,” Gurss said.
He said that although there are no assurances that the $500 million pledged by Nextel would be enough, there are indications that Nextel and others might add to that sum, and that there could be some incentives for them to do that.
“I thought it would be useful to show you what the plan is in a nutshell. That might play into plans for P39’s future,” Gurss said.
The compromise plan would allow for some low-site, cellularized operations on rebanded frequencies, but its crafters said that they took a careful approach in hopes of preventing a recurrence of interference from such systems that the plan is intended to resolve. The plan adopts similar limitations on such systems as those embodied in technical rules for the 700 MHz Guard Band. It restricts those operations in such a way that only smaller systems used in “campus-type” operations might be expected to fit the description.
Gurss said that even with a frequency relocation, the FCC still would have to adopt clear rules about interference prevention, codifying best practices, to apply before, during and after frequency relocation.
“Rebanding won’t be a perfect solution. Public safety still will have intermodulation interference problems with Nextel,” he said. Gurss said that unless the industry submitted a compromise proposal, it would be unlikely to expect the FCC to act in a timely manner, citing the agency’s well-known preference of consensus plans brought before it by industry participants. He said that predicting the timing of an FCC decision is impossible, and that he did not expect the commission to take any further step in the proceeding before the end of the year.
FCC decision timetable
“I don’t think the document flow into the commission has stopped. For example, the consensus plan says that its signatories would provide more information, including border issues and funding, for example. Plus, the FCC is not a court. It receives a constant flow of information. When it issues an order of some type in this matter, I don’t think it will be final. It may take the form of a report and order and further notice. Or the FCC could put one or more of these plans out for comment, but I think that would be a waste of time,” Gurss said.
Gurss said that some wireless carriers would like to see all public safety operations moved to the 700 MHz band. One reason is that the carriers are unhappy with their own allocation in that band, believing it to be less satisfactory for 3G cellular services than higher frequencies.
“Moving public safety to the 700 MHz band that involves a whole range of legislative actions including clearing TV stations and raising billions of dollars to pay for it. But even though the compromise 800 MHz rebanding plan and moving public safety to 700 MHz seem mutually exclusive, there has been some talk where the consensus plan is seen as one stage, with public safety moving to 700 MHz at a later time,” Gurss said.
Gurss said that moving public safety to 700 MHz is beyond the FCC’s jurisdiction.
“It would require going to Congress. APCO’s filing says FCC has to address this interference problem and has to do it under its statutory authority without waiting for congressional action, and that means no move to 700 MHz. That doesn’t mean we reject all the ideas in the wireless carriers’ plan—for example, we still favor clearing the 700 MHz band of TV stations.”
Kearns, who manages the Information and Telecommunications Services Division for King County, Washington state, brought up the matter of coordinating frequency changes in border regions near Canada.
Alan S. Tilles, an attorney with Shulman, Rogers, Gandal, Pordy & Ecker, Washington, told the committee that the compromise plan accommodates all frequency changes without conflict with Canada “except for 20 channels in Buffalo, N.Y.” Tilles represents the Personal Communications Industry Association and a number of clients with FCC radio communications licenses that would be affected by frequency changes.
Interference reporting tool
APCO’s Web-based 800 MHz interference reporting tool, which was created before P39, continues to offer helpful information despite its limitations as a text file that does not allow computerized analysis.
The information isn’t necessarily as accurate or detailed as we might like,” Kearns said.
Kearns said that the P39 committee had some discussions about housing the reporting tool to the National Law Enforcement and Corrections Technology Center at the University of Denver. He said that NLECTC seemed willing, but lacked funding to carry on the data collection and analysis. That wouldn’t solve P39’s problem, because APCO can house the reporting tool, and APCO’s problem is with funding, too.
A committee participant, Bernie Olson, said that the reporting tool lacks a method for passing along the root causes of interference and solutions that might follow.
Gray told the committee that the reporting tool isn’t standardized in a way to allow adequate comparisons.
Ron Hasareth, director of APCO’s Automated Frequency Coordination, said that it wouldn’t take too much work to modify the front-end reporting and to create a follow-up mechanism, and that APCO could do that with existing resources. He said that existing information could be used to ask people who submitted data to respond with a follow-up. Joe Kuran, the technical systems manager for Washington County (Ore.) Consolidated Communications, said that he didn’t think reporting agencies would take the time to revisit their interference reports and submit follow-ups.
Tilles said that the Land Mobile Communications Council might take responsibility for the reporting tool if its scope were expanded to catalog all 800 MHz, not merely public safety. He said that Olson previously had mentioned that a limitation of the tool is that it cannot capture interference before it happens.
“I took message to LMCC and said that in the frequency coordination process, we might catch this type of intermod before it occurs,” Tilles said.
He said that a mechanism was possible whereby a licensee that notices fresh interference could check a database to find what had changed in the operating environment.
“You could go on one of the coordinators’ sites and type in a query and get a printout of a database of cellularized systems within a radius of where you’re looking. That’s a kind of notification or way to check yourself. I think I can get the frequency coordinators to do that because they are supposed to resolve post-licensing conflicts. I think I can convince them to have a companion to their search engine that has a similar database where you can report interference. Then when someone else does a frequency search, it would be possible to pull up all of the interference reports within a radius of that area,” Tilles said.
It can’t be said that as the committee meeting drew to a close and Kearns repeated his call for participants to express themselves about P39’s future that there was a clamor for continuing the work. Kearns said that he would verify with the APCO board of officers whether P39 is on the right track, reach out to other stakeholders beyond APCO with an interest in the project, and organize some conference calls that include participants besides the Technical Committee.
“I want to recognize all people who got us to this point today on the Technical Committee. We’re moving [toward resolving interference] today, not just because of us, but we’ve played a role and can be proud of what we have accomplished. Now it’s time to take it to the next level,” Kearns said.
Vincent Stile, APCO’s first vice president, told the meeting that P39 should continue working in conjunction with APCO’s Spectrum Management Committee.
“We should keep the P39 committee together because things are coming along where we will need it. Speaking as a member of the P39 Steering Committee and as a board officer, we’re thankful for your work,” Stile said.